قیمت گذاری انتقالی با انگیزه مالیات و قیمت های تجارت درون بنگاهی ایالات متحده

This paper analyzes monthly data on US international trade prices between 1997 and 1999 in order to investigate the impact of tax influences on intrafirm trade prices. Results indicate that there is substantial evidence of tax-motivated transfer pricing in US intrafirm trade prices. There is a strong and statistically significant relationship between countries’ tax rates and the prices of intrafirm transactions. Controlling for other variables that affect trade prices, as country tax rates are lower, US intrafirm export prices are lower, and US intrafirm import prices are higher. This finding is consistent with theoretical predictions regarding tax-motivated income shifting behavior.

Approximately 40% of all US international trade is intrafirm trade, or international trade that occurs within the firm. This paper utilizes monthly data from the Bureau of Labor Statistics (BLS) on international trade prices in 1997, 1998, and 1999 to undertake an empirical investigation of US intrafirm trade prices. It finds important differences in the behavior of intrafirm trade prices when compared with arms-length trade. Most importantly, the use of this hitherto unutilized data set allows for a direct test of the influence of tax-motivated income shifting on US intrafirm trade. Multinational firms can effectively shift income to more lightly-taxed locations by manipulating transfer prices on intrafirm transactions. There is a large literature that has considered indirect evidence of transfer pricing (see Hines (1997) for a review), relying on statistical relationships between country tax rates and affiliate profitabilities or tax liabilities. However, this is the first comprehensive study to consider direct evidence of how the prices of intrafirm transactions differ from those of non-intrafirm transactions. 1 The paper finds evidence of tax motivated income-shifting that is consistent with theoretical expectations and robust to different approaches and specifications. As country tax rates are lower, US intrafirm international trade transactions exhibit lower export prices, and higher import prices, than non-intrafirm trade transactions. This is consistent with theoretical expectations regarding multinational firms’ tax-minimizing behavior. These results are found using both statutory and effective tax rates as explanatory variables, and controlling for other influences that may affect trade prices.

This paper has analyzed monthly data on US international trade prices between 1997 and 1999 in order to investigate the behavior of intrafirm trade prices. Results find direct evidence indicating that intrafirm trade prices are likely influenced by the tax-minimization strategies of multinational firms. In particular, there is a strong and statistically significant relationship between a country’s tax rate and the prices of intrafirm imports and exports traded with that country. The estimates in Table 4 indicate that a tax rate 1% lower in the country of destination/origin is associated with intrafirm export prices that are 1.8% lower and intrafirm import prices that are 2.0% higher, relative to non-intrafirm goods. Estimates that employ effective tax rates find smaller but still important tax effects. This evidence is particularly noteworthy in the context of a large empirical literature on tax-motivated transfer pricing that has relied almost entirely on indirect evidence. This research suggests an agenda for further work. For instance, further research can use these results as a starting point to estimate the impact of this tax motivated transfer-pricing on US federal government tax revenues. For instance, to what extent does tax-motivated transfer pricing shift income away from the United States? Is income also shifted toward the United States, away from high-tax countries? What are the consequences for the magnitude of US corporate income tax revenue collections? There are also interesting questions outside the scope of public finance. Intrafirm trade has been found to respond differently to tax and exchange rate variables. Such findings have important implications for those interested in understanding the determinants of international trade patterns.